Hello, everyone. Welcome to another edition of Envera at the Board (E@TB). Today we’re going to talk about six ways to ensure that you have an annual emission report (AER) that’s not only accurate but is also properly submitted.
In our experience working with annual emission reports, there are a number of common areas people overlook, and these areas have the ability to affect the accuracy of the overall report.
[00:40] Importance of having an accurate report
Being that you’re in the middle of report preparation, it’s important that you understand what these common areas are so that you don’t accidentally end up compromising the accuracy of your own report or, if you’re having a consultant prepare your report for you, that your consultant doesn’t end up making some of the mistakes we’ve seen in the past.
[01:07] 2015 report specifics
This year, the report is due to the South Coast Air Quality Management District (AQMD) on Tuesday, March 1, at 5:00 p.m.. In addition, the AQMD will be having a number of workshops at their facility in Diamond Bar, where they will go over some of the details and some of the changes related to the 2016 report. If you’re interested in attending those workshops, you can go to the AQMD on January 12 at 1:00 p.m.; January 14 at 9:00 a.m.; January 21 at 9:00 a.m.; and January 27 at 1:00 p.m. These workshops are always well-attended, and they share a lot of good information about what has changed with the reporting tool. They also let you know if there have been any programmatic changes to the report that will be rolled out this year.
One of these changes is that the AQMD has updated its guidance documents on organic liquid storage tanks, dairy and poultry operations, and polyester resin operations. If you have a facility that has an organic liquid storage tank, or you have a facility that is a dairy or poultry operation or a polyester resin operation, you’ll want to check out these guidance documents that were updated in December; they may impact your facility.
Let’s look at the six ways to ensure that your AER is accurate and properly submitted.
[03:10] 1) Ammonia emissions
The first common area that gets overlooked when people prepare annual emission reports relates to a facility’s ammonia emissions, which are the result of the combustion of fuel. On the annual emission report, there are several default emission factors that are used to calculate the emissions of ammonia from the combustion of fuel. The problem occurs because people don’t use the proper emission factor when calculating the emissions for the annual emission report. More specifically, they end up using a default emission factor that doesn’t accurately describe their equipment. They end up using a default emission factor for a piece of equipment that has the wrong control device on it.
The default ammonia emissions within the AER are broken down into two groups: the internal combustion and the external combustion. In each of these categories, the ammonia emission is further characterized by the type of control device found on each piece of equipment. You’ll therefore have a default emission factor for an internal combustion engine with an SCR, an ammonia default emission factor for an internal combustion engine for a piece of equipment that has an SNCR, and a default emission factor for an internal combustion engine with no control device. On the external combustion equipment, you’ll have the same thing: the external combustion equipment with an SCR, one with an SNCR, and one with none.
People tend to make the mistake of selecting the wrong default emission factor for their piece of equipment simply because they don’t know what kind of control device is attached to their equipment. There are two ways to know what the control device is: you can look at your permit, or you can look at the piece of equipment. Regardless what method you use, you’ll want to be sure that when you’re calculating your ammonia emissions from either your external or internal piece of equipment, you use the correct default emission factor.
On top of that, we find that the reporting software has several default emission factors for all of the aforementioned cases. The default ammonia emission factor in the AER software typically describes equipment most people don’t have. The default ammonia emission factor in the reporting tool describes internal combustion equipment with an SCR, but most engines don’t have an SCR. If you’re quickly moving through the reporting tool, you may select the wrong default ammonia emission factor, and then you may end up overestimating your ammonia emissions.
Again, be sure to select the correct ammonia emission factor.
[06:46] 2) RECLAIM fuel usages
You also want to be sure that the fuel usages on your annual emission report match the fuel usages you use to prepare your Regional Clean Air Incentives Market Program (RECLAIM) reports. Again, the RECLAIM program is a regional cap and trade program for knocks and socks in the South Coast Air Quality Management District. If you’re in the RECLAIM program, you’re required to submit to the AQMD quarterly or annual reports of your NOX and/or SOX emissions. Those reports are going to be based on fuel usages, and you need to maintain all of the documentation so that you back up all of the calculations you end up submitting.
The problem we see is that when people prepare annual emission reports for a RECLAIM facility, they end up taking the fuel usages for the combustion equipment from a source that’s different from the source that was used to prepare the RECLAIM emissions. When people do that, the fuel usage that’s calculated on the AER differs from the fuel usage that was calculated to report the emissions under the RECLAIM program. Again, you’ll want to be sure that the fuel usages you use for your AER match those that were used to prepare the quarterly RECLAIM reports.
In addition, you want to be sure that you subtract any AER-exempt sources. For example, PERP equipment, or equipment that’s registered under the California Portable Equipment Registration Program, permits those emissions it be exempt under the AER. You don’t want to report the PERP emissions that are in your reclaim reports under the AER because that’s an exempt emission source.
As a general formula to report emissions on your AER is the sum of all of the fuel usages used to prepare your quarterly report subtracting any AER-exempt equipment. That’s going to require you to go through the reports and look at all of the different sources that were reported under the reclaim reports and then figure out which sources are exempt under the AER program.
[09:50] 3) AER-exempt compounds
You’ll want to be sure that you’re not reporting any AER-exempt emissions sources on your report. We talked about the portable equipment for the RECLAIM fuel usages and that you have to subtract that when you’re using that RECLAIM fuel usage on your AER.
What are some of the other AER-exempt fuel sources or emissions sources? One is architectural coatings. As a group, architectural coatings are an exempt emission source. However, you’ll need to report architectural coatings on your AER if the architectural coating is part of the production process. In general, the use of architectural coatings within a facility is exempt.
Any sort of compounds or emission points that are exempt under SCAQMD Rule 102 don’t need to be reported. The most common compound exempt under Rule 102 is acetone. Also, mobile sources aren’t reported on your AER. You don’t need to report the emissions from portable equipment on your AER.
Again, be sure that you don’t report exempt emission sources on your AER.
[11:30] 4) Using source test results
If you want to use any source test results on your AER, be sure the source tests were approved for use. What we commonly see is that people will report their emissions from a piece of combustion equipment, but rather than using the default emission factors for combustion, they’ll use a source test report because they want to get a more accurate emission profile from that piece of equipment. That’s okay, but you’ll want to be sure that your source test is approved before you use it on your emission report.
You will need to have had a source test that occurred prior to 2016 that went through the entire approval process: protocol, notification, report submittal, report review, receipt of confirmation, or approval letter. Only when a source test is approved can you use it to calculate emissions for your annual emission report. If the source test results are not approved, you’re going to have to revert to the default emission factor or the source test, or use the source test that was last approved.
Again, be sure that your source test results are approved prior to using them on your annual emission report.
[12:58] 5) The use of facility-specific sampling data
Where possible, be sure that you use facility specific sampling data. A lot of times when calculating emissions on an annual emission report, people will use default emission factors. That’s fine if you don’t have any other data set available, but environmental compliance programs are often fairly complex. They have a lot of different regulations, and within those regulations there will be a lot of reporting and monitoring requirements. What we typically find is that when operating a fairly complicated and large environmental compliance program, you’re going to almost always be required to collect samples from your process to fulfill some other reporting requirement.
Some of the cases we see are collecting material samples for a toxic release inventory (TRI) report, collecting waste water samples for a self-monitoring (SMR) waste water report, or collecting samples for hazardous waste profiles to manage hazardous waste. If you have all of this facility specific data, you should use it when calculating emissions for your annual emission report. You can use this data in conjunction with the standard emission calculation techniques and formulas.
One way we see this as a benefit is when you’re reporting emissions from cooling towers. Interestingly, reporting emissions from cooling towers using the default emission factors will produce emissions that grossly overestimate the process. We’ll link to a few studies that have noted this and have tried to derive corrections for this overestimate. But the best thing you can do, if you have a cooling tower, is collect the data needed to use the facility specific data within the standard emission calculation formulas.
You may also be able to use facility specific data from other regulatory programs that calculate emissions on your annual emission report.
Again, be sure to use facility specific data on your annual emission report if you can.
[15:47] 6) Prepare a complete submission
Submitting an annual emission report requires two things: do an electronic submission using the reporting tool, and submit a hard copy to the AQMD, along with wet signatures on the form and a check if your fees are due.
We’ve seen all sorts of variations on what gets submitted. Maybe they’ll submit the electronic report but not the hard copy report. Maybe they’ll submit the hard copy report but not the electronic report. They may submit the electronic report and the hard copy report, and then maybe they’ll forget a signature or maybe they’ll forget the forms.
Again, you want to be sure you submit a complete report. That means you’ve done the electronic submission, you’ve printed out the forms from the electronic submission and you’ve had them signed by a responsible official at your facility, and then, if fees are due, you submit the signed forms along with a check, all to the AQMD by March 1.
So there you have it: six ways to ensure that your annual emission report is not only accurate but that it’s submitted properly. Let’s run through the list one more time:
- Be sure that your ammonia emissions are correct by using the right default emission factor, which is dependent on the kind of control equipment installed to that piece of equipment (i.e., either an external or internal combustion device).
- Be sure that the fuel usages used on your AER match those that were used to prepare the RECLAIM reports.
- Be sure that you’re not reporting or calculating emissions from any exempt or AER-exempt emissions sources: architectural coatings, any emission source that emits compounds that are exempt under Rule 102, mobile sources, and portable equipment.
- Be sure that a source test is approved prior to using it on the annual emission report.
- When it’s possible, use facility specific data you may have in your annual emission report. To find this data, you may have to look in other regulatory programs like a TRI, the waste water program, the storm water program, or hazardous waste profiles.
- Be sure your submission is complete. A complete submission consists of an electronic submission using the reporting tool, and a hard copy submission that includes the printed and signed forms and a check, all of which is submitted to the AQMD.
We’re trying to provide you some value so that when you prepare your 2016 annual emission report, you know some of the pitfalls or common areas people tend to overlook that affect the accuracy.
If you have any questions, you can reach out to us at Envera Consulting. Otherwise, we’ll see you in the next video.
Let’s take this over to you.
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